Corrective Action Plans

The food pantry acknowledges the finding and agrees with the recommendations. The responsible officials have committed to implementing the following corrective actions: develop and implement a comprehensive inventory management policy that includes the requirement for an annual physical inventory of donated foods, schedule and conduct the annual inventory observation for the current fiscal year and ensure it is completed by the end of the fiscal year, provide training to staff involved in the inventory process to ensure they understand and follow the new procedures and perform periodic internal audits to ensure ongoing compliance with the inventory management policy and address any issues identified.

Edit Check Worksheets will be matched to requests for State of NJ Division of Agriculture reimbursement on a monthly basis for accuracy.

Planned Corrective Action: The Department of Public Instruction (DPI) will complete and submit reports for subaward information in the FFATA Subaward Reporting System (FSRS) for the Child Nutrition Cluster (CNC) starting in fiscal year 2025. The internal processes established to ensure proper reporting of subaward information did not include payments made for Child Nutrition Cluster grants, as the Department did not believe the FFATA requirement applied to these awards. Upon notification that DPI is required to include these awards, the written policies and procedures are being updated to include processes to identify which subawards and subrecipients have exceeded $30,000 and complete the monthly FFATA reporting as required. Anticipated Completion Date: Person responsible for corrective action: Michael Brendel, Assistant Director School Financial Services Team Division of Finance and Management Department of Public Instruction michael.brendel@dpi.wi.go

Finding 2024-001 Written Procurement Polley- This finding impacts the procurement and suspension and debarment compliance requirement for the major program, Assistance Listing Number 10.555 National School Lunch Program (Child Nutrition Cluster) funded by the Commonwealth of Massachusetts Department of Elementary and Secondary Education (DESE). Nurtury should revise its procurement policy to comply with Uniform Guidance requirements and implement policies and procedures to search for suspended or debarred vendors on Sam.gov. Fiscal Year 2025. Procurement policy is in accordance with Uniform Guidance requirements. Management and the finance committee of the board will ensure that revised procurement policies are in accordance with Uniform Guidance requirements. Tubi Olatubosun, V.P. of Finance

Description of Corrective Action Plan: Shoals Community School Corporation’s Director of School Nutrition, Tamara Florio, will ensure that all time cards are signed by the employee and by herself before submitting to the Payroll Administrator, Darla Holt. Responsible Party and Time and Timeline for Completion: Tamara Florio, Director of School Nutrition-this will be implemented immediately, this 2024-2025 school year.

Boston Public Schools Food and Nutrition Services has begun implementing advanced policies including additional segregation of duties and additional documentation to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

The School Corporation will establish an internal control process to esnure detailed records are maintained and an audit trail is evident to comply with federal compliance requirements. The Treasuer and the Deputy Treasurer will oversee the implementation of the corrective action plan, which will go into effect immediately.

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Material Noncompliance, Qualified Opinion Condition and Context: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. During the testing of internal controls over eligibility determinations via the application process and related compliance, we noted the School Corporation was not able to provide the application or any documentation to support the eligibility status for 6 out of the 8 applicant students selected for tested for the 2022-2023 school year. There were no issues identified for students selected for testing whose eligibility was directly certified. Additionally, for the 2023-2024 school year, for 2 out of 30 students selected for the testing, the income eligibility determinations were not properly implemented. One student was determined to be eligible for "Free" meals per their free/reduced application but, the School Corporation incorrectly entered the eligibility as "Reduced" within the food service software. Another student was eligible for "Reduced" benefits per the direct certified download file but was entered into the food service software as eligible for "Free" benefits. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, the corporation will take more time in reviewing free and reduced applications to ensure student free or reduced status is listed correctly and supporting documentation is maintained. Applications are now completed online limiting paper copies. A review of applications by another member of the corporation staff will also be conducted. Responsible Party for Corrective Action: Terri Roesler, Treasurer, will oversee the implementation of the corrective action plan. Timeline for Completion: Immediately.

FINDING 2024-003 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Summary of Finding: The School Corporation did not have effective internal controls in place to ensure contracted vendors were not suspended or debarred or otherwise excluded from participation in federal award programs. The School Corporation could not provide evidence of verification for Resolve Tech during the engagement period. Contact Person Responsible for Corrective Action: Teresa Whitesel Contact Phone Number and Email Address: 765-358-4006 twhitesel@wes-del.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Corporation Treasurer was not aware of this requirement. This will be completed by the next audit period of FY2025 FY2026

FINDING 2024-004 Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the cash management compliance requirement. Context: In a sample of 5 monthly claims for reimbursement selected for testing, the following compliance exceptions were noted: • Management failed to submit the April 2023 claim for reimbursement in a timely manner (within 90 days) to the IDOE and was not reimbursed for meals served as a result. • For the other 5 claims tested, the number of meals claimed did not agree to the supporting meal system reports. There was a gross overstatement of meals claimed of $21,189 and a gross understatement of meals claimed of $538.35 resulting in a net over-reimbursement of $20,650.47. We noted that the School Corporation has a secondary review control in place designed to review claims prior to submission to the IDOE. However, the control was not operating effectively to detect and prevent errors in the amount claimed for reimbursement. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management has revised and implemented a more thorough control process over the preparation and submission of the monthly claims for reimbursement. A reconciliation sheet has been created and implemented for verification and will be completed every month. Responsible Party and Timeline for Completion: Jessica Defossett and Kendra Franks, January 2025

FINDING 2024-003 Subject: Child Nutrition Cluster - Internal Controls over Eligibility Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Franklin County Community School Corporation has transitioned to the Community Eligibility Provision (CEP) as an alternative to collecting, approving, and verifying household eligibility applications. Responsible Party and Timeline for Completion: Jessica Defossett, September 2024 transition to CEP

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement Procurement Audit Finding: Material Weakness Condition and Context: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirement. The School Corporation utilizes two vendors for the majority of food and supplies purchases for the food service program. One vendor is procured through a purchasing cooperative, Southwest Indiana Co-op, where the School Corporation is a member. The other vendor met the simplified acquisition threshold for fiscal year 2023 and the small purchase threshold for fiscal year 2024. The School Corporation was unable to provide any supporting documentation for the procurement process undertaken as required by the School Corporation's procurement policy. Management stated the items purchased were chosen based on a comparison of prices with two other vendors, however, management had no documented support for the rationale or process to determine which vendor would be selected for food and supplies purchases. The sample item amount disbursed was $151,511 for food purchases in FY23 and $129,583 for food purchases in FY24. The School Corporation did properly confirm the vendor was not debarred or suspended. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The treasurer will provide the food service director with quarterly vendor reports so the spending thresholds can be monitored. In the event it is known that expenditures will exceed the threshold, the food service director will work to provide rationale for the vendor choice and/or procure items using the bid/RFP process. Responsible Party for Corrective Action: Tamara L. Asdell, Treasurer Timeline for Completion: Immediately

Department: Education Administrative and Financial Services Title: Internal control over CNC cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has developed and implemented new procedures to confirm that batch payments are paid on time. Completion Date: March 15, 2025 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC donated food inventory needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will follow up on open CNPWeb tickets for completion. The Department will work with the vendor to create a new computerized system to receive tickets and print them automatically to remove the manual process of writing tickets. The Department will initiate meetings each month to compare inventory numbers, if they do not match. The Department will work with the vendor to replace any missing item from their inventory with an equal product each month. Completion Date: March 31, 2025 first item, December 1, 2025 second item and April 30, 2025 third and fourth item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over the submission of CNC Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has updated the SEFA Review Procedure to include more specific information regarding the calculation of amounts reported for the Special Milk Program and noncash assistance and the classification of payments made to a school as direct payments rather than subrecipient expenditures. Completion Date: March 10, 2025 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will implement a monthly status check of the current tracking tool to ensure compliance with the review The Department will update the current high-risk procedure. The Department will develop a procedure for evaluating base year reviews and add a procedure for timelines for adjustments to the claims. Completion Date: July 1, 2025, September 1, 2025, and June 1, 2025, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.555 $1,605 ALN 10.582 $9,535 ALN 10.559 $117,259 Likely: Undeterminable Status: Corrective action in progress Corrective Action: Child Nutrition Services will create a procedure for reviewing applications and making sure they are approved prior to participation. For the Summer Food Service Program (SFSP), the Child Nutrition Services will create an additional application, outside of CNPWeb to further assess non-congregate operations and eligibility to prevent duplicative services. Child Nutrition Services has submitted a ticket to create an edit check on the SFSP Application to ensure that all specific eligibility information is submitted. Child Nutrition Services will create a procedure to address that session specific information is received prior to claim approval for sites. Child Nutrition Services will require a site sheet for SFSP applications for each location and each enrollment period. Child Nutrition Services will submit a ticket to CNPWeb to allow for documentation to be added to the site information sheet when revisions are made to the system. Child Nutrition Services will add documentation to the activities tab, while we wait for the enhancement to be completed. Child Nutrition Services will create a procedure to ensure that allocations to schools fall between $50.00 - $75.00. Child Nutrition Services has provided training to the National School Lunch Program reviewers on the Fresh Fruit and Vegetable Program questions within the Administrative Review process to ensure that those questions are asked during the Administrative Review. Completion Date: May 1, 2025, first and fourth items, April 1, 2025, second, fifth, sixth, and seventh items, June 1, 2025, third item, March 1, 2025, eight item, and February 10, 2025, for nineth item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.559 $628,924 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will create procedures for Application Approvals with site classification, eligibility and non-congregate plan requirements. The Department will develop procedures for Revisions on Claims and Applications. For the Summer Food Service Program, the Department will request an edit check enhancement in CNPWeb to add actual enrollment be added to claims. Completion Date: May 1, 2025, first and second item, and May 1, 2026, third item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

FINDING 2024-004 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Child Nutrition Cluster- Internal Controls Contact Person Responsible for Corrective Action: Brian Leitch, Holly Singleton and Roger Urick Contact Phone Number and Email Address: 260-347-2502 bleitch@eastnoble.net, hsingleton@eastnoble.net rurick@eastnoble.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The monthly meal reimbursement claims are calculated by the Food Service Director (Roger Urick) with documentation from Meal Magic. The document is printed and reviewed by the Deputy Treasurer (Holly Singleton). Both parties sign the report, and it is recorded. Reimbursement is submitted by the Food Service Director (Roger Urick). Once reimbursement is received, the Deputy Treasurer (Holly Singleton) gives updates to the Food Service department to verify that the amounts received match the amounts requested. The Director of Food Service uses the Federal Income Guidelines to input into the Meal Magic software. The Deputy Treasurer oversees him inputting the information and they both sign the documentation verifying the numbers in the system. When the Director of Food Service downloads the direct certification monthly and enters them into Meal Magic, a report will be ran by the Food Service secretary to verify that the certified students were properly processed. Documentation of the state’s report and the meal magic report will be signed and retained as evidence. Anticipated Completion Date: The corrective action plan regarding reporting has been established since the 2023-2024 fiscal year. The corrective action plan regarding eligibility will be established immediately.

FINDING 2024-003 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Brian Leitch, Holly Singleton and Roger Urick Contact Phone Number and Email Address: 260-347-2502 bleitch@eastnoble.net, hsingleton@eastnoble.net, rurick@eastnoble.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Any contracts or vendors with an excess of $25,000, documentation will be requested stating that the company is in good standing (the company is not suspended or debarred from receiving Federal Funds). The site Sam.gov may also be utilized to verify the company is complaint. This information is included in New World with the quote. A binder with companies that have been verified from the Sam.gov site is available for the Deputy Treasurer, Grants Coordinator and Food Service to reference. Any new vendors are added to the list and the list is printed every 6 months. Anticipated Completion Date: Immediately

FA 2024-002 Strengthen Controls over Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: None Identified Prior Year Finding: None Identified Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's suspension and debarment procedures were followed. Corrective Action Plans: The School District will evaluate and improve internal control procedures to ensure that vendors are not suspended or debarred, or otherwise excluded prior to entering covered transactions and required suspension and debarment documentation is properly retained. Management will develop a monitoring process to ensure that these procedures are operating appropriately. Estimated Completion Date: June 30, 2025 Contact Person: Debbie Woerner, Finance Director/Asst Superintendent Telephone: 770-567-8489 ext. 1030 Email: woerned@pike.k12.ga.us

FA 2024-001 Strengthen Controls over Transfers Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $803,845.92 Prior Year Finding: None Identified Description: The polices and procedures of the School District were insufficient to provide adequate internal controls over transfers of Child Nutrition Cluster funds. Corrective Action Plans: The School District will review current internal control procedures related to School Nutrition Fund transfers. Development and/or modification of current policies and procedures will be determined as needed to ensure that all expenditures, including transfers, are used for allowable purposes. In addition, the School District will implement a monitoring process to ensure that all expenditure activity is compliant with the School District's policies and procedures. Estimated Completion Date: June 30, 2025 Contact Person: Debbie Woerner, Finance Director/Asst Superintendent Telephone: 770-567-8489 ext. 1030 Email: woerned@pike.k12.ga.us

Response and Corrective Action Plan: The District will implement a process to retain all documentation of eligibility in the program as outlined by the Iowa Department of Education and Office of Management and Budget.

Response and Corrective Action Plan: The District will implement a process to retain all documentation of charges to the program as outlined by the Iowa Department of Education and Office of Management and Budget.

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Annette Brown Contact Phone Number and Email Address: 812-829-2233 annettebrown@socs.k12.in.us Views of Responsible Officials: We concur with this finding that a more thorough and more fully documented process should be in place and that it needs to cover the full school year and not be done just the one time towards the beginning of the year. Description of Corrective Action Plan: The􀀃Technology􀀃and􀀃Food􀀃Service􀀃Reporting􀀃Assistant􀀃(TFSRA)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃the􀀃initial􀀃processing􀀃of􀀃applications􀀃and􀀃 Direct􀀃Certification􀀃(DC). The􀀃Claims/Deputy􀀃Treasurer􀀃(C/DT)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃a􀀃random􀀃check􀀃on􀀃applications􀀃to􀀃confirm􀀃that􀀃eligibility􀀃is􀀃applied􀀃 accurately. This􀀃check􀀃should􀀃happen􀀃four􀀃(4)􀀃times􀀃a􀀃year: 1. Around􀀃the􀀃Fall􀀃Membership􀀃Count􀀃Day􀀃(first􀀃few􀀃days􀀃in􀀃October)􀀃 2. Christmas􀀃Break􀀃(around)􀀃 3. Spring􀀃Break􀀃(around)􀀃 4. First􀀃part􀀃of􀀃May􀀃 The􀀃TFSRA􀀃will􀀃put􀀃the􀀃list􀀃of􀀃students􀀃and􀀃their􀀃eligibility􀀃from􀀃the􀀃food􀀃service􀀃software􀀃(currently􀀃Titan)􀀃at􀀃the􀀃point􀀃of􀀃each􀀃 check.􀀃The􀀃first􀀃pull􀀃of􀀃students􀀃in􀀃October􀀃will􀀃be􀀃all􀀃students􀀃while􀀃the􀀃subsequent􀀃pulls􀀃will􀀃be􀀃for􀀃the􀀃dates􀀃between􀀃the􀀃 previous􀀃pull􀀃and􀀃that􀀃date􀀃with􀀃the􀀃intention􀀃of􀀃catching􀀃any􀀃new􀀃students􀀃or􀀃new􀀃student􀀃eligibility. The􀀃C/DT􀀃will􀀃select􀀃a􀀃random􀀃sampling􀀃of􀀃students􀀃to􀀃verify.􀀃They􀀃will􀀃work􀀃with􀀃the􀀃TFSRA􀀃to􀀃look􀀃at􀀃the􀀃records􀀃in􀀃Titan􀀃for􀀃 applications􀀃and􀀃CNPWeb􀀃for􀀃the􀀃DC􀀃students􀀃to􀀃see􀀃applications􀀃or􀀃the􀀃DC􀀃eligibility􀀃as􀀃appropriate.􀀃Forms􀀃will􀀃be􀀃printed􀀃or􀀃 screen􀀃shot􀀃to􀀃create􀀃a􀀃file􀀃that􀀃will􀀃be􀀃saved􀀃by􀀃both􀀃parties. Anticipated Completion Date: March 14, 2025